Most pilots with migraines can achieve FAA medical certification. The keys are headache frequency, treatment choice, and medication no-fly timing — all of which determine whether you qualify for the streamlined CACI pathway.
Informational Use Only. The information on this page reflects our understanding of current FAA medical certification requirements and is provided for general educational purposes only. FAA policies and the AME Guide are updated frequently. The FAA AME Guide is the authoritative source in all cases. Nothing here constitutes legal or medical advice. Always verify with your AME and at faa.gov/ame_guide.
Migraine is a CACI Condition
Migraine and chronic headache qualify as Conditions AMEs Can Issue (CACI) for all three classes of medical certificate — provided all worksheet criteria are met. This means many pilots with migraines do not need to submit to the FAA for approval; a HIMS or Senior AME can issue the certificate at the time of examination. Cases that do not meet CACI criteria require deferral and FAA Special Issuance review.
The FAA distinguishes between headache types and severity. Identify your scenario to understand your certification pathway.
Occasional stress/tension headaches — controlled with OTC meds, fewer than 2 days/month
Migraine (with or without aura) — on acceptable medications, ≤1 episode/month
Migraine — currently using triptans or other abortive medications
Migraine — on preventive medications (beta blockers, CGRP, CCB)
Migraine with disabling visual symptoms, large visual field cut, or retinal migraine
Complicated/post-traumatic migraine, vestibular migraine, or chronic daily headache
Headaches associated with neurological findings, syncope, or TIA-type symptoms
The FAA's concern is twofold: incapacitation risk and medication impairment. A severe migraine in the cockpit can be completely disabling, and many common migraine medications — including narcotics, triptans, and some preventives — carry sedation, cognitive impairment, or cardiovascular risks that are unacceptable in flight. The FAA evaluates both the headache pattern itself and every medication used to treat or prevent it.
To qualify for CACI issuance, your treating physician's clinical progress note (generated within 90 days of your exam) must confirm ALL of the following:
Must be migraine (with or without aura), tension headache, or cluster headache. Post-traumatic headache, vestibular migraine, retinal migraine, and complicated migraine do NOT qualify for CACI.
No more than ONE episode per month. Additionally, no more than 2 outpatient or urgent care visits in the past 12 months for headache exacerbation, and no inpatient hospitalizations for headaches.
Symptoms must be mild and non-disabling. No visual impairment (excluding normal aura), no vertigo, no syncope, no mental status change, no neurological deficits, no TIA-type symptoms, and no auras occurring WITHOUT headache.
The condition must be stable on the current treatment regimen with no management changes recommended by the treating physician.
ALL medications — both abortive and preventive — must be on the FAA's approved list. Narcotics, Fiorinal, Fioricet, Midrin, tramadol, TCAs, and anticonvulsants are NOT acceptable. Each medication requires a completed ground trial.
Observe post-dose no-fly periods: most triptans 24 hours; eletriptan/frovatriptan 48 hours. For Nurtec, Ubrelvy and Zavzpret used for occasional migraine relief/rescue, the September 30, 2026 FAA AME Guide specifies 24 hours after the last dose. Daily rescue use is not acceptable under this pathway. Completing the waiting period does not override impairing symptoms, medication side effects, or other certification requirements.
These waiting periods begin after the last dose, not the onset of the headache. They apply even if symptoms have fully resolved. Nurtec (rimegepant), Ubrelvy (ubrogepant), and Zavzpret (zavegepant): 24-hour no-fly period after the last dose when used for occasional migraine relief/rescue, per the September 30, 2026 FAA AME Guide. Daily rescue use is not acceptable under this pathway. Completing the waiting period does not override impairing symptoms, medication side effects, or other certification requirements. The current migraine worksheet does not specify a universal waiting interval for the OTC analgesics listed below; do not fly with impairing symptoms or medication side effects.
Most Triptans (sumatriptan, rizatriptan, zolmitriptan, etc.)
Eletriptan (Relpax) & Frovatriptan (Frova)
Ubrelvy (ubrogepant) — occasional relief/rescue only; not daily rescue use
Nurtec (rimegepant) / Zavzpret (zavegepant) — occasional relief/rescue only; not daily rescue use
Metoclopramide (Reglan)
Promethazine (Phenergan)
Narcotics, Fiorinal, Fioricet, Midrin, Tramadol
OTC analgesics (ibuprofen, acetaminophen, aspirin, naproxen) — no flying with impairing symptoms or side effects
Using an unacceptable medication (Fioricet, narcotic, tramadol) — automatically disqualifying and requires Special Issuance
Not completing a ground trial for a new medication before returning to flight duties
Flying during the no-fly waiting period after an abortive medication — a serious FAA violation
Auras occurring WITHOUT headache — this pattern is a specific CACI disqualifier requiring neurological evaluation
More than one headache episode per month — even one extra episode makes you CACI-ineligible
Failing to document all medications — including OTCs, NSAIDs, and supplements used for headaches
Clinical progress note older than 90 days — the FAA requires the note be generated within 90 days of your exam
Vestibular migraine or retinal migraine incorrectly categorized as 'common migraine' — these are deferral conditions
Preventive medication started but no ground trial documented — each new medication requires its own trial period
Not disclosing prior migraine history on Form 8500-8 — non-disclosure is far worse than the condition itself
Official FAA sources used in developing this guide.
What sets our practice apart for migraine and headache certification cases.
Medication Review Before Your Exam
We review every medication on your list — abortive and preventive — before your exam to identify any FAA-unacceptable medications and advise on alternatives with your treating physician.
Ground Trial Documentation
We help you document completed ground trials appropriately in your medical record so there is no ambiguity at your exam about when you may resume flying.
Pilot Perspective
As an active ATP pilot, Dr. Scott understands the real-world challenge of the no-fly waiting period and can advise on practical approaches that remain FAA-compliant.
CACI vs. Deferral Guidance
We assess whether your headache pattern meets CACI criteria before your exam, so you arrive prepared — not surprised by a deferral at the last minute.